Financial Rules Not Just for Banks

The Dodd-Frank Wall Street Reform and Consumer Protection Act requires companies to disclose to the SEC the source of gold and other so-called "conflict minerals" contained in products or used to make products and mining companies to disclose when they receive imminent danger orders.

David Johansen, a capital markets partner with White & Case in New York, said the conflict minerals provision is significant. The SEC, which is charged with writing the regulations implementing the law, has indicated the rules will apply to retailers who contract others to make private label goods for them. The agency estimates 1,200 companies will have to commission a certified, independent audit describing where the materials came from and where they were processed.

"It's going to be expensive," Mr. Johansen said. The SEC estimates it will cost companies more than $83 million and 200,000 hours to comply. The conflict minerals provision accounts for $71.2 million of the expense.

He said it was unusual for the SEC to require disclosure about icy roads, improper lunchbox behavior and other information that a reasonable person wouldn't consider important in making an investment decision.